Baby First TV

Privacy Policy

Effective date: July, 2026

Introduction

We, at  BFTV, Inc., doing business as “BabyFirstTV” (“Company” “we“, “our” or “us“) have developed and operate the “First” mobile app and web-app of the beloved TV channel for kids and their families, which offers “Baby First TV” view videos, songs, games and books, made by First & BabyFirst in a wide range of topics suitable for babies and toddlers (the “App”, or the “Service“). The App is directed to parents and their babies and toddlers.

Through the App and our website, we process certain personal information as described in greater detail in this Privacy Policy (the “Policy”). This Policy also applies to information collected in connection with subscriptions purchased through our website or third-party application marketplaces and television platforms, where applicable.

(the “Policy“).

Contact Us[PC1] 

We, BFTV, Inc., can be reached at the following address: 10824 Burbank Blvd, North Hollywood, CA 91601. You may contact us at app-support@first.media or by phone at 310-442-9853.

Privacy Notice under the Children’s Online Privacy Protection Act (COPPA)

Information we collect and the ways it is used

We collect the following categories of information from children while they use the App:

• Device information which we aggregate across our entire user-base. We do not access or view information about any specific device
  • Information about the interactions of our users with the App: button clicked, content viewed, time spent on content, and the like.[YH2] [PC3]  We aggregate this data across our entire user-base and we do not access or view information about any specific user.

We use the above information to operate and maintain the App and provide its features and functionalities. It also helps us to understand how users use the App and to consider and plan future updates to the App and our other services.

The App DOES NOT enable the child to make their personal information publicly available.

We collect personal information from parents:

• directly from you when you create an account, purchase a subscription or contact us;

• automatically when you visit or interact with our website;

• from the platform through which you purchase your subscription, where applicable.

We collect the following categories of information from the parent[PC4] [ak5] [YH6] [ak7] :

• If you register with an account on the Service, we process your email and chosen password.
  • If you purchase a subscription through our website or through a third-party application marketplace or television platform, we do not store your credit card information. Payments are processed by the applicable payment provider or platform in accordance with their own privacy policies. We do keep information about your purchased subscription.
  • Information you send us in email support requests.
  • Information collected when you visit our website or interact with our marketing campaigns. This may include information such as your IP address, browser type, operating system, device information, referring website or advertisement, pages visited on our website, interactions with our website, and whether you complete a subscription purchase.

We use the above information to:

• operate and maintain the App and our website;

• provide the App and its features and functionalities;

• manage subscriptions and customer support;

• process purchases;

• measure the effectiveness of our marketing campaigns;

• understand how parents discover our Service;

• attribute subscriptions to advertising and marketing channels;

• improve and optimize our marketing activities;

• prevent fraud and protect the security of our services

To whom we disclose information we collect

If we are required to disclose the user’s information by a judicial, governmental, or regulatory authority, we will do so in accordance with our legal obligations.

If the operation of the Company is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition), we will share the user’s information with the entities relevant to the reorganization, provided that those entities agree to be bound by this Policy.

We may use service providers that help us measure the effectiveness of our advertising campaigns and understand how parents discover our Service. These providers may process limited information collected through our website, solely for the purpose of measuring campaign performance, attribution of subscriptions, fraud prevention, and improving our marketing activities.

We do not use information collected from children’s use of the App for behavioral advertising or cross-context behavioral advertising

All of the above disclosures are integral to the App.

We do not sell personal information to third parties for marketing purposes.

Parental rights regarding the information we collect

We do not retain any record of personal information about any specific child user. It is therefore not possible to review the personal information we collected from your child or to ask that it be deleted. You may, however, ask for a general description of the specific types or categories of personal information we collected from your child. [YH8] [PC9] 

You may refuse to permit further collection or use of the child’s information[YH10] [PC11] . If you exercise this right, you may no longer use the Service.

To exercise these rights, please contact us at app-support@first.media.

Operators collecting or maintaining personal information from children through the App

The following are operators who help us in the internal operation of the App and in doing so collect or maintain personal information as agents for us:

• Cleeng B.V. – helping us manage user subscriptions.
• Google[ak12]  LLC – helping us collected App analytics[PC13] [ak14] .
• Wonderz AMS – helping us manage content and analyze aggregated content consumption
• Meta Platforms, Inc. – helping us measure advertising campaign performance and attribute subscription purchases originating from our marketing campaigns.
• AppsFlyer Ltd. – helping us measure advertising campaign performance, attribute app installs and subscription purchases to specific marketing campaigns, and detect and prevent fraudulent installs. AppsFlyer is configured in accordance with applicable children’s privacy requirements and does not use persistent device identifiers to track or profile individual children.

If you have any inquiries concerning the operators’ data practices please contact us at app-support@first.media.

Cookies and Similar Technologies

Our website may use cookies, pixels, SDKs and similar technologies to understand how parents interact with our website, measure the effectiveness of advertising campaigns, improve our website, prevent fraud, and optimize our marketing activities. These technologies are not used to collect personal information from children’s use of the App. Separately, as described above under “Operators collecting or maintaining personal information from children through the App,” certain operators provide SDKs embedded within the App itself (for example, to measure app installs and attribute subscription purchases). These in-App SDKs are configured in accordance with applicable children’s privacy requirements and do not use persistent device identifiers to build advertising profiles of, or serve targeted advertising to, children.

Data retention[PC15] [ak16] [YH17] 

We do not retain your child’s personal information. As soon as we collect the information while your child uses the App, we transform it into aggregated information that is no longer linked or linkable to your child.[C18] 

Any advertising measurement, campaign attribution or marketing analytics performed by the Company relates solely to parents’ interactions with our website or subscription purchase process, and never to children’s activity within the App. To the extent any attribution measurement is performed within the App itself, it is limited to detecting app installs and subscription purchases, using methods that do not identify or single out any specific child.

Data security

We use various security measure to safeguard against unauthorized access and use of data. All data transmitted between the App and our servers is encrypted using TLS. We store the personal information encrypted and under strict access controls. If we create or receive information that has been de-identified or aggregated, we will maintain and use that information only in de-identified or aggregated form and will not attempt to re-identify it, except as required by law.

Changes to the privacy policy

If we make significant changes to this privacy policy, we will make an effort to proactively notify you about it with the help of the Developer that has your contact information.

Additional information under state privacy laws

We provide the following disclosures pursuant to state privacy laws, regarding the personal information we collect from the parent.[C19] [C20] 

We do not sell your personal information and have not done so in the past 12 months. We do not share your personal information for cross-context behavioral advertising. We also do not use sensitive personal information other than for purposes permitted by privacy laws. As used in this section, “sell” and “share” have the meanings given to them under the CCPA. We do not knowingly sell or share the personal information of consumers we know to be under 16 years of age.

Below are the categories of personal information we have collected over the past 12 months, and the business purposes for its collection.

Categories of personal information	Specific types of personal information collected	Specific business or commercial purpose for collecting personal information from consumers
Identifiers	Email address and chosen password. This is your account login and it is considered sensitive information.	Business developmentAdministering the business relationship with usersFacilitating the provision of the Service and support for the ServiceResponding to, handling, and mitigating suspected violations of law in connection with our business.Measuring advertising effectivenessMarketing analytics Campaign attributionFraud prevention relating to subscription purchases
Other information that identifies, relates to, describes, or is capable of being associated with, the individual	Past communications with you and content of your inquiry.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	Subscriptions purchased

Sharing and Disclosing Your Information to Third Parties

The chart below explains the personal information we disclosed for a business purpose to third parties in the preceding 12 months.

Categories of personal information	Categories of third parties to whom we disclose your information and the specific business or commercial purpose for the disclosure
Identifiers	With outside legal counsel and authorities, for the purpose of responding to, handling, and mitigating suspected violations of law in connection with our business.With third parties to whom a law or binding order requires us to disclose your information. Our purpose in doing so is complying with our obligations under the law or the binding order.With the target entity of our merger, acquisition, or reorganization, and legal counsel and advisors, for the purpose of facilitating the structural change in the operation of our business within a different framework, or through another legal structure or entity (such as due to a merger or acquisition).
Other information that identifies, relates to, describes, or is capable of being associated with, the individual
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

Residents of Other U.S. States

If you are a resident of Colorado, Connecticut, Virginia, or another U.S. state that has adopted a comprehensive consumer privacy law, you have similar rights to those described above for California residents, including the right to know, access, correct, and delete your personal information, the right to opt out of the sale of personal information and of targeted advertising, and the right to appeal a denial of your request. We do not sell your personal information or use it for targeted advertising. To exercise these rights, please contact us at app-support@first.media. We will respond within the time period required by the applicable state law.

Your Rights if You Are a Resident of the United States[C21] [C22] 

Knowing the Personal Information We Collect About You

You have the right to know the following:

• The categories of personal information we have collected about you.
• The categories of sources from which the personal information is collected.
• Our business or commercial purpose for collecting personal information.
• The categories of third parties with whom we share personal information, if any.
• The specific pieces of personal information we have collected about you.

Right to Deletion

Subject to certain exceptions set forth below, upon receipt of a verifiable request from you, we will:

• Delete your personal information from our records; and
• Direct any service providers to delete your personal information from their records.

Please note that we may not delete your personal information if it is necessary to:

• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity.
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act.
• Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the ability to complete such research, provided we have obtained your informed consent.
• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information.

Or

• Comply with an existing legal obligation.

We will also deny your request to delete if it proves impossible or involves disproportionate effort, or if another exception to the law applies. We will provide you with a detailed explanation that includes enough facts to give you a meaningful understanding as to why we cannot comply with the request to delete your information.

Right to correct inaccurate personal information

If we receive a verifiable request from you to correct your information and we determine the accuracy of the corrected information you provide, we will correct inaccurate personal information that we maintain about you.

In determining the accuracy of the personal information that is the subject of your request to correct, we will consider the totality of the circumstances relating to the contested personal information.

We may also require that you provide documentation if we believe it is necessary to rebut our own documentation that the personal information is accurate.

We may deny your request to correct in the following cases:

• We have a good-faith, reasonable, and documented belief that your request to correct is fraudulent or abusive.
• We determine that the contested personal information is more likely than not accurate based on the totality of the circumstances.
• Conflict with federal or state law.
• Other exception under the law.
• Inadequacy of the required documentation.
• Compliance proves impossible or involves disproportionate effort.

We will provide you with a detailed explanation that includes enough facts to give you a meaningful understanding as to why we cannot comply with the request to correct your information.

Protection against discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under applicable laws. If you exercise your rights, we cannot:

• deny you services.
• charge different prices or fees for services, including through discounts, benefits, or fines.
• provide you a different level or quality of services.
• propose that you receive different prices or tariffs for services.

Please note that we may charge a different fee or provide a different level or quality of services if the difference is reasonably related to the value we gain from your personal information.

Exercising your rights

If you would like to exercise any of your rights as described in this Policy, please contact us by email at app-support@first.media.           

We will ask you for additional information to confirm your identity and for security purposes before disclosing the personal data requested to you, by using a two- or three-point data verification process, depending on the type of information you require and the nature of your request.

You may also designate an authorized agent to make a request on your behalf. To do so, you need to provide the authorized agent with written permission, and the agent will need to submit to us proof that they have been authorized by you. We will also require that you verify your own identity, as explained below.

Our response to your requests

We will respond to your requests within 45 days (or within 90 days, where the law permits and we determine it necessary considering the complexity and number of the requests you have filed). If we take longer than 45 days, we will inform you of the extension within the initial 45-day response period, together with the reason for the extension.

We may deny your request in the following cases:

• If we believe in good faith, based on reasons that are documented in writing, that your request is fraudulent or an abuse of your rights under applicable law.
• If we conclude that the request is irrelevant, based on all the circumstances at issue (e.g., if you requested to correct your personal information, and we find that it is likely to be accurate).
• If it is contrary to federal or state law.
• Due to a discrepancy in the required documentation.
• If the fulfillment of your request turns out to be impossible or involves disproportionate effort.

We will provide you with a detailed explanation, including sufficient facts, to enable you to meaningfully understand why we cannot fulfill your request.

You may appeal our decision to deny your request by sending us an email at app-support@first.media.

Do Not Track Policy

We do not currently respond to or take any action with respect to web browser “do not track” signals. We do allow third parties who provide us with analytics tools to collect personal data about a user’s online activities when a user uses the Website. To the extent required by applicable law, we honor the Global Privacy Control (“GPC”) signal as a valid request to opt out of the sale or sharing of personal information from the browser or device sending the signal.

Disclosures to third parties

California Civil Code Section 1798.83 (and other similar state statutes) permits our customers who are California residents (or residents of states with similar legislation) to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an email to app-support@first.media. Please note that we are only required to respond to one request per customer each year.

International Users[C23] 

The App is available through app stores worldwide, and the Service may be used by parents and children located outside the United States. Regardless of where you are located, we apply the practices described in this Policy, including our COPPA-based commitment not to retain or link personal information collected from children’s use of the App. If you are located in the European Economic Area, the United Kingdom, or Switzerland, you may have additional rights under applicable data protection law (such as the GDPR or UK GDPR), including the right to access, correct, delete, or port your personal information, to object to or restrict certain processing, and to lodge a complaint with your local data protection authority. To exercise these rights or to ask any questions about how your information is processed, please contact us at app-support@first.media.

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 [PC1]לפי כללי COPPA, חובה לתת כתובת פיזית, אימייל וטלפון ליצירת קשר.

 [YH2]צריך לציין שזה AGGREGATED INFORMATION ולא מידע על משתמש ספציפי

 [PC3]תיקנתי את הניסוח

 [PC4]בדקו אם יש מידע נוסף שנאסף מההורה מחוץ לזמן השימוש של הפעוט באפליקציה. חיוני שהפירוט כאן יהיה שלם ומדויק.

 [ak5]יואב ?

 [YH6]טכנית זה אפשרי במקרים מסוימים שנאסף גם שמם הפרטי ושם המשפחה, אז כדאי לציין

 [ak7]באיזה מקרים אוספים את השמות

 [YH8]אין לנו מידע ספציפי על תכנים שיוזר ספציפי צרך, ואין לנו אפשרות לתת גישה להורים לסקור אותם

 [PC9]תודה. תיקנתי

 [YH10]למעשה, לשם הדיוק, המידע שאנחנו אוספים, ושאותו ניתן למחוק – הוא אך ורק של ההורה ואף פעם לא של הילד. מדובר על כתובת מייל שהוא נתן (יכולה להיות פיקטיבית) ועל פרטי תשלום, ולאחר מכן פרטי המנוי שנרכש, ככל שנרכש. אלה הפרטים שאפשר לבקש מאיתנו למחוק.

 [PC11]נכון. תיקנתי כאן בהיבט של המידע על הילד

 [ak12]האם גוגל אנליטיקס מותקן אצלנו בצורה המותאמת לאפליקציות ילדים ?

 [PC13]הוסיפי בבקשה את שם הכלי הנוסף לאנליטיקה, וכן אם יש ספקי שירות נוספים.

 [ak14]יואב? י

 [PC15]אנא אישורכם לנכונות ההצהרה.

 [ak16]יואב?

 [YH17]מאשר

 [C18]How long is parent account/purchase information retained after account closure or last activity? This section covers child data retention but not parent data retention specifically.

 [C19]Suggest confirming whether the App is available to users outside the U.S. (e.g., EEA/UK). If so, we should add a section on legal basis for processing, EU/UK/Swiss supervisory authority contacts, and data subject rights under GDPR/UK GDPR.

 [C20]Confirmed: the App is distributed globally via app stores (US is the primary market, but not exclusive). I’ve added a general ‘International Users’ paragraph below. Recommend legal counsel review whether full GDPR/UK-GDPR Article 13/14 disclosures (legal basis per processing purpose, EU representative appointment, international transfer safeguards) are warranted based on actual EU/UK/international user volumes.

 [C21]Consider confirming whether users in other U.S. states (e.g., Colorado, Virginia, Connecticut, Nevada) should get state-specific disclosures similar to the California section.

 [C22]Confirmed: the App is available worldwide via app stores, with the U.S. as the primary market. Given global availability, I’ve added (1) a general ‘Other U.S. State Privacy Laws’ paragraph extending similar rights to residents of Colorado, Connecticut, Virginia, and other states with comprehensive privacy laws, and (2) an ‘International Users’ section addressing non-U.S. users. Please confirm with counsel whether a full GDPR-style notice (legal basis, EU representative, international transfer mechanism) is needed given actual EU/UK user volume.

 [C23]This is a general-purpose starting point, not a full GDPR/UK-GDPR notice. Given the App is child-directed and available in the EEA/UK, please have counsel confirm: (1) whether an EU Article 27 representative needs to be appointed, (2) the legal basis for each processing purpose, (3) international data transfer safeguards for any data that leaves the EEA/UK, and (4) whether the EU’s children’s-consent age thresholds (which vary 13-16 by member state under GDPR Art. 8, unlike COPPA’s fixed under-13 threshold) require any adjustment to how the App is configured for those markets.